Filed: Feb. 17, 2016
Latest Update: Feb. 17, 2016
Summary: STIPULATION REGARDING DISCOVERY AND MOTION DEADLINES WILLIAM H. ORRICK , District Judge . Plaintiff Mark Migdal and Defendant AMCO Insurance Company, through their undersigned counsel, hereby stipulate as follows and respectfully request that the Court approve and give effect to their stipulation: WHEREAS, AMCO's counsel requested proposed dates for Plaintiff's deposition in early December 2015 and renewed that request on January 7, 2016; WHEREAS, Plaintiff responded that, due to his exte
Summary: STIPULATION REGARDING DISCOVERY AND MOTION DEADLINES WILLIAM H. ORRICK , District Judge . Plaintiff Mark Migdal and Defendant AMCO Insurance Company, through their undersigned counsel, hereby stipulate as follows and respectfully request that the Court approve and give effect to their stipulation: WHEREAS, AMCO's counsel requested proposed dates for Plaintiff's deposition in early December 2015 and renewed that request on January 7, 2016; WHEREAS, Plaintiff responded that, due to his exten..
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STIPULATION REGARDING DISCOVERY AND MOTION DEADLINES
WILLIAM H. ORRICK, District Judge.
Plaintiff Mark Migdal and Defendant AMCO Insurance Company, through their undersigned counsel, hereby stipulate as follows and respectfully request that the Court approve and give effect to their stipulation:
WHEREAS, AMCO's counsel requested proposed dates for Plaintiff's deposition in early December 2015 and renewed that request on January 7, 2016;
WHEREAS, Plaintiff responded that, due to his extensive travels outside the country, the first date on which he could be available for deposition would be during the week of February 22, 2016;
WHEREAS, the parties have now scheduled Plaintiff's deposition for March 3, 2016;
WHEREAS, the parties wish to allow sufficient time following Plaintiff's deposition for follow-up discovery;
WHEREAS, a brief continuance of the discovery and dispositive motion deadlines in this case will not impact the September 19, 2016 bench trial date in this matter;
IT IS HEREBY STIPULATED AND AGREED THAT the case management schedule should be revised as follows:
Current Deadline New Deadline
Non-expert discovery cut-off: April 8, 2016 June 10, 2016
FRCP 26(a)(2) expert disclosures: April 22, 2016 May 20, 2016
FRCP 26(a)(2) rebuttal disclosures: May 10, 2016 June 7, 2016
Expert Discovery cut-off: June 10, 2016 July 8, 2016
Dispositive pre-trial motion hearing cut-off: June 10, 2016 August 8, 2016
Pretrial conference statements: June 24, 2016 August 15, 2016
Pretrial conference: July 11, 2016 August 22, 2016
ORDER
This Stipulation is DENIED without prejudice. The parties shall incorporate their scheduling requests in the Joint Case Management Conference Statement due on March 1, 2016 and be prepared to discuss this at the hearing on March 9, 2016.
